In the case of Corinne Mill Canal and Stock Company v. Johnson in 1894, the United States Supreme Court ruled on a dispute over water rights between two parties in Utah. The plaintiff, Corinne Mill Canal and Stock Company, claimed that they had prior appropriation to use water from Bear River for their mill operations. However, the defendant, Johnson, argued that he had acquired riparian rights to use this same water for his farming activities by virtue of owning land adjacent to it. The court decided in favor of Johnson based on established principles of Western Water Law which prioritized agricultural uses over industrial ones when there was a conflict over scarce resources such as water. This ruling affirmed the importance of local customs and practices in determining property rights disputes even when these may differ from common law traditions.

In the dissenting opinion for Corinne Mill Canal and Stock Company v. Johnson, it was argued that the majority had erred in their interpretation of Utah's water laws. The dissenting justices believed that under these laws, a person who first appropriates water and puts it to beneficial use has superior rights over subsequent users. They contended that this principle should apply even if the initial user did not construct any works or improvements on the land where they diverted the water from its natural course. Therefore, according to them, Johnson’s right to use of water should be upheld as he was using it before Corinne Mill Canal and Stock Company began their operations despite his lack of physical infrastructure at source point.